DRAFT

Supporting Statement

for

Information Collection Request

Motor Vehicle Emissions:

Revisions to Certification of Alternative Fuels Conversions 

EPA ICR 0783.55

April 2010

Compliance and Innovative Strategies Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency
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Part A SUBMISSION 

Section 1: Identification Of The Information Collection

1(a) Title And Number Of The Information Collection

Motor Vehicle Emissions: Revisions to Certification of Alternative Fuels Conversions;

EPA ICR number 0783.55, OMB control number 2060-0104.

1(b) Short Characterization/Abstract

The Environmental Protection Agency is proposing changes designed to simplify

and lessen the burdens for manufacturers seeking approval to introduce into commerce in 

the U.S. light-duty vehicles, light-duty trucks, medium-duty passenger vehicles, and heavyduty vehicles and engines that have been converted for use of fuels that the original models 

were not designed for, such as from gasoline to liquid propane gas (LPG) or compressed 

natural gas (CNG). This ICR covers the light-duty portion of the proposal. These 

applications are currently administratively handled as a part of EPA’s motor vehicle and 

engine certification program, covered by the ICR 0783 series. This ICR addresses the 

anticipated paperwork burden reduction of the proposal within the context of the existing 

baseline from OMB 2060-0104 (ICR 0783.54), which was approved on August 31, 2009.

These changes would start taking effect with 2011 model year light-duty vehicles

and trucks or upon the effective date of the final rule. Starting then, manufacturers will be 

given expanded options for submitting simplified applications. ICRs normally have a three 

year time horizon. This ICR will cover the expected paperwork burden changes for the 

three years after the effective date of the final rule. 

Information collected under the existing alternative fuels conversion program

consists of test results and related submissions under existing procedures for the EPA lightduty vehicle certification program. All information from converter applicants is currently

submitted electronically directly to the Verify system. Subject to confidentiality claims, 

this information is made available to interested parties upon request. Emission test 

information is available on the internet.

The burden analysis in this ICR differs from the cost analysis in the preamble to the 

proposed rule in important respects. First, ICRs are concerned with paperwork burdens, a 

subset of all business costs: this ICR covers the costs and labor hours of providing 

information to EPA, including both the paperwork itself and the costs and labor to develop 

the information, such as testing to provide test results, and facilities to carry out that 

testing. It is not concerned with the costs of compliance in general, nor with general 

business overhead or profits. The preamble, on the other hand, focuses on costs incurred in 

developing conversions that comply with the Clean Air Act and subsequent certification 

applications through contracts by converters with testing companies, which include 

overhead and profit elements not counted in the 0783 series. The analysis in this ICR uses 

the traditional capital cost, O&M cost, and labor cost assumptions in this ICR series, so 
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that, for example, facility costs that would be recovered as part of a consulting firm's 

contract are here allocated to capital costs. Second, the preamble focuses on the burden for 

a single converter enterprise of interest (and generalizes this to four such enterprises). This 

ICR attempts to generalize the analysis to the industry as a whole. Third, the ICR does not 

cover development costs associated with compliance with the Clean Air Act, but only the 

paperwork-related costs once such a conversion has been achieved to the point where the 

converter submits an application for certification. 

The existing baseline estimates that certification applications for 36 test groups 

from five converter respondents are submitted annually. The most recent model year data 

available (model year 2008) shows 18 light-duty vehicle conversions. This ICR adjusts the 

baseline to 18 conversions and calculates industry savings against that number. The 

analysis also gives the change in the 0783 ICR overall collection. 

These test groups consist of conversion kits that apply to a specific certified OEM 

(original equipment manufacturer) vehicle engine family, or in some cases group of 

families. As with OEM certifications, the biggest paperwork cost component for converters 

is testing. However, estimating testing costs under the existing regulations has been

difficult because the alt. fuel converter program encompasses a diverse range of 

circumstances. Many of the tests are currently waived in certain situations. For example, 

currently, evaporative testing may or may not be waived depending on whether a closed 

fuel system is used. Exhaust and evaporative emission testing can be waived for dualfueled gasoline/LPG or gasoline/CNG vehicles if the modification doesn’t increase the 

weight more than 500 pounds and no increase in emissions is expected. (Assumptions for 

dealing with these complexities both in the existing program and under the proposal are 

discussed in Section 6.) 

The current baseline applied to 18 test groups estimates an industry total paperwork 

cost of $137,856. As with the main light-duty program, this does not include development 

costs (such as repeated testing needed to perfect a conversion kit that can meet emission 

and OBD standards), which are not directly mandated by the Clean Air Act but which can 

be considerable. Other elements of the alt. fuels certification process covered by this ICR 

are listed in Part 4 below, including paperwork filing burdens, which are budgeted in the 

ICR as O&M costs and labor hours. Converted vehicles are also, as with other certified 

vehicles, subject to EPA's confirmatory testing program, durability demonstration, Vehicle 

Emission Control Information (VECI) labeling, defect and voluntary emission recall 

reporting, and other light-duty requirements (all covered in ICR 0783). In addition, they are 

subject to EPA’s certification fee requirements (ICR2080; OMB 2060-0545) but burden 

changes in this program is de minimis (the number of fee forms affected is small and will 

be reflected in the next fees ICR renewal). All burden elements in this ICR are in the 

Emissions (Certification) IC. 

The proposed changes will recognize three classes of conversions: to (1) vehicles 

that are new or relatively new, (2) vehicles within EPA’s definition of useful life but which

are neither new nor relatively new (“intermediate life vehicles”), and (3) vehicles that are 

outside EPA’s definition of useful life. For the newest vehicles, certification will still be 
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required, but with some additional flexibilities and expansion of options. Conversion of 

intermediate life vehicles will be not be certified but audited through reporting of a 

simplified testing demonstration that the converted vehicle family still meets emissions 

standards certified for the OEM vehicle family. For conversion of outside useful life 

vehicles EPA intends to finalize a single demonstration requirement but is seeking 

comment on three options. 

Beginning in model year 2011 or the effective date of these regulations, the 

proposed changes will reduce total costs annually on the regulated manufacturers by

$50,667 in non-labor costs and 7,073 labor hours.

Additional details on the coverage of this ICR are given in Section 2(b), below. 

Section 2: Need For And Use of the Collection

2(a) Need/Authority For The Collection

Under Title II of the Clean Air Act (42 U.S.C. 7521 et seq.), EPA is charged with 

issuing certificates of conformity for motor vehicle designs that comply with applicable 

emission standards set under section 202(a)(1) of the Act. A manufacturer must have a 

certificate before vehicles may be legally introduced into commerce. To insure compliance 

with the Act, EPA reviews product information and manufacturer test results; EPA also 

tests some vehicles to confirm manufacturer results. 

Section 203 of the Clean Air Act contains “anti-tampering” provisions prohibiting 

alteration of OEM vehicle components relevant to the vehicle’s certification under the Act. 

Regulations at 40 CFR, Part 85, Subpart F, provide exemption for aftermarket conversion 

systems from these tampering prohibitions for those converters complying with the 

regulations of that Part. Under Subpart F, these exemptions are currently administered 

through a certification process that is modeled on the OEM certification provisions: 

converters submit certification requests for engine families, and those that satisfy EPA’s 

regulations upon review are granted certificates of conformity for one model year. 

2(b) Practical Utility/Users of the Data

The information collection under the rule would be used to determine whether the 

new requirements have been complied with by means of the revised certification and 

compliance program. 

Section 3: Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

The information collection, reporting, and storage provisions of the proposed rule 

rely to the maximum extent possible on EPA’s existing certification program, while 

simplifying that program to reflect the needs of this industry.
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Efforts have been made to eliminate duplication in this information collection. 

EPA-CISD (Compliance and Innovative Strategies Division) is currently using, for lightduty vehicles, a new information management system (Verify), under which the 

manufacturer submission process will occur within a Central Data Exchange (CDX) 

environment that should further help minimize duplication in submissions.

Because of its specialized nature and the fact that product plans and emission 

performance information must be submitted to EPA prior to the start of production, this 

information is not available from any source other than the manufacturer.

3(b) Public Notice Prior to ICR Submission to OMB

EPA solicited public comment by means of a Federal Register Notice published on ____, 

2010, __ Federal Register ___; a copy can be found at _____________ . The draft ICR was 

placed in the docket. 

3(c) Consultations

The proposed regulations, including the cost analysis that is reflected in this ICR, 

were developed based on experience with similar regulations developed in the past in close 

consultation with the affected industry. In designing this proposal EPA sought and 

received significant input and feedback from the fuel conversion community. 

In preparing the proposed rule, EPA made use of consultations with several 

converters and an independent test lab working in the regulated industry:

Their comments have been considered in developing the burden estimates discussed 

below. EPA wishes to thank them and their colleagues for their assistance in preparing this 

report.

3(d) Effects of Less Frequent Collection

As required by the Clean Air Act (42 USC 7525(a)), emission information is 

currently submitted on a yearly basis coinciding with the manufacturer’s “model year.”

EPA allows applicants to define their own “model year”, thus granting some flexibility in 

this regard. Major product changes typically occur at the start of a model year. For these 

reasons, a collection frequency longer than a model year is not possible normally possible. 

However, this rule would replace the annual application and compliance process with a 

one-time submittal for intermediate and outside useful life vehicles. Furthermore, for new 

and relatively new vehicles, when a vehicle design is “carried over” to a subsequent model

year, the amount of new information required is substantially reduced.

3(e) General Guidelines

Manufacturers are required to keep some records for periods longer than three years
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This requirement stems from the statutory requirement that manufacturers warrant some 

items for periods longer than 3 years. 

This information collection activity complies with the remaining guidelines in 5 

CFR 1320.5. The proposal makes no changes in the reporting and recordkeeping 

provisions that impact any of the guidelines for information collections as approved in the 

existing approved collection.

3(f) Confidentiality

Information submitted by manufacturers is held as confidential until the specific 

vehicle to which it pertains is available for purchase. After vehicles are available, most 

information associated with the manufacturer/importer’s application is available to the 

public. Under section 208 of the Clean Air Act (42 USC 7542(c)) all information, other 

than trade secret processes or methods, must be publicly available. Proprietary information 

is granted confidentiality in accordance with the Freedom of Information Act, EPA 

regulations at 40 CFR Part 2, and class determinations issued by EPA’s Office of General 

Counsel.

3(g) Sensitive Questions

No sensitive questions are asked in this information collection. This collection 

complies with the Privacy Act and OMB Circular A-108.

Section 4: Respondents and Information Requested

4(a) Respondents/NASIC Codes

The respondents are potentially involved in the industries shown in the following 

table:

Industry 335312A

336312

336322

336399

454312

485310

Alternative fuel vehicle converters

A North American Industry Classification System (NAICS)

4(b) Information Requested

(i) Data items

The information and reporting burden associated with this rule occurs within the 

context of EPA’s motor vehicle certification and compliance program. Current regulations 
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require converters to submit emissions information to EPA in conjunction with this 

program. Converters of newer vehicles must submit an application for emission 

certification prior to production. Intermediately aged vehicle converters will submit a 

simplified testing demonstration without the burdens of the formal certification application 

process. For vehicles converted outside their useful life, regulation will be through an 

information submission that the conversion is technically viable and will not increase 

emissions. These reporting formats describe the major aspects of the proposed product 

line, technical details of the emission control systems, and the results of any required tests 

to indicate compliance with the emissions limitations. The reports and supporting test 

results are reviewed and, if appropriate, a certificate of conformity is issued, the applicant 

is notified of possible noncompliance with anti-tampering provisions, or additional postproduction information is requested. 

New/revised data items:

At the time of certification:

For all vehicles: 

 expanded conversion test or "demonstration" groups

 exemption from HCHO testing for conversions to CNG and 

LPG 

 conversion factors for calculating NMOG for conversions to 

CNG and LPG 

 new VECI label requirement describing test group, mileage, 

and date

For intermediate-age and outside useful-life age vehicles (25%)

 online notification and test result report rather than application 

for certification (savings in “paperwork” burden) or 

compliance “demonstration” for outside useful-life conversions

 description of OBD compliance strategy or OBD 

demonstration rather than current OBD test results

(ii) Respondent Activities

While there is no “typical” converter respondent, all converters must describe their 

product and supply test data and other information to verify compliance. In some cases the 

proposal would replace the current application and certification process with a notification 

and audit process. Applicants for certification submit certification fees, usually “reduced 

fees” set at 1% of the estimated retail sales value of the conversion package, including 

labor. Converters or installers of conversion kits must install a second VECI label on 

converted vehicles. Converters must also retain records. These tasks are repeated for each 

model year, although typically previous data and information can be “carried over” when 

no significant changes have occurred. 

Section 5: The Information Collected—Agency Activities, Collection Methodology, and 

Information Management
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5(a) Agency Activities

The test data used by EPA to determine compliance with emissions standards are

derived from vehicle testing done by vehicle converters who report their own test data to 

EPA, and at EPA's National Vehicle and Fuel Emissions Laboratory in Ann Arbor, 

Michigan. EPA staff review applications (or notifications or demonstrations), issue 

certificates, and oversee the program. 

5(b) Collection Methodology and Management

All information from converter applicants will be submitted electronically directly

to the Verify system by the effective date of the new rule. By guidance letter CISD-09-14, 

vehicle converters are required to submit applications for certification through Verify

beginning with the 2010 model year. The rule makes no changes in this reporting system, 

only changing the format and content of some of the information reported within it. 

All information received by EPA is subject to review. Data submitted are screened

to determine that the test results insure compliance with emission and fuel economy

standards. Narrative descriptions of the proposed product line are checked to verify that 

the appropriate "worst case" vehicles have been tested. Except for projected sales and a 

very limited amount of proprietary product information, all information is available to the 

public as soon as the vehicle is offered for sale. Emission data are available on the

internet; other information is available upon request under the Freedom of Information Act.

5(c) Small Entity Flexibility

Converters already enjoy various exemptions and special provisions tailored to their 

small entity status and special business needs in contrast to original vehicle manufacturers, 

such as use of assigned deterioration factors, exemption from the manufacturers’ in-use 

vehicle testing program (IUVP) and availability of reduced certification fees. This proposal 

further extends this flexibility in numerous ways detailed in the proposal and summarized 

in this Supporting Statement. 

5(d) Collection Schedule

Currently, information must be submitted for each “model year” that a manufacturer 

intends to convert vehicles. Under the proposal, only the newest vehicles will be required 

to renew annually, but all categories will file an end-of-year report (as do light-duty

manufacturers). For emissions purposes, a “model year” is statutorily defined as the annual 

production period of a manufacturer, as decided by the Administrator, that includes January

1 of that calendar year; or that calendar year if the manufacturer does not have an annual 

production period. If a product is unchanged between model years, much of the 

information can be “carried over.” The collection frequency and burden are determined to 

a large extent by the manufacturer’s marketing and production plans.
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Section 6: Estimating the Burden and Cost of the Collection

The following estimates of reduced burden use baselines and methodologies 

developed in the process of continuing updates of the 0783 ICR series, including the last 

renewal (ICR 0783.54), and the proposed greenhouse gasses rule (ICR 0783.56). The 

reasoning behind estimates of decreased burden from the current baseline are given below 

and summarized in Section 6(f). 

6(a) Estimating Respondent Burden (Hours)

As noted above, the number of converter test groups covered by the ICR is subject 

to small number fluctuations. The baseline in the last renewal (ICR 0783.54) was 36 test 

groups; in the renewal three years before that (ICR 0783.47) it was 15. Following normal 

practice, the baseline is here adjusted to reflect the most current information available; we 

count 18 light-duty conversion test groups for Model Year 2008. The Emissions IC will 

reflect this adjustment. The discussions below compare the burdens on 18 families before

and after the proposal. 

Within the converter program under the adjusted baseline, the respondent hours 

burden decrease for the Light-Duty Vehicle Emissions Information Collection reflects 

reduced labor hours associated with conducting tests and reduced reporting. This is largely

due to the broader definition of test groups, since this definition determines how many tests 

must be conducted. The paperwork reporting burdens in particular are significantly reduced 

for intermediate and out of useful life conversions. As converters are a very small subset of 

the current light-duty baseline (currently 18 out of 427 test groups/engine families), the 

decrease in burden is correspondingly small; but for vehicle converters the hour savings are 

significant (from 14,869 hours down to 7,796 hours, a savings of over 40%). 

In particular, the number of test groups requiring any reporting under this rule is 

estimated to be reduced by 25 percent. This correspondingly reduces the labor hours 

associated with conducting emissions tests (including preparation costs, FTP tests, NMOG 

tests and HFET tests), OBD compliance reporting, confirmatory testing costs (including 

shipment costs), and paperwork reporting and recordkeeping costs associated with 

preparing this information in any of the required formats and submitting it to EPA for 

review and saving it for possible submission to EPA upon request. Intermediate and beyond 

useful life conversion test groups are estimated to achieve an additional 80 percent 

reduction in paperwork reporting for those qualifying.

The ICR includes a minor startup cost for implementing new labeling requirements. 

All labor hours associated with startup costs are treated as capital/startup costs, so they are 

included under that heading, following EPA guidance (EPA ICR Handbook, Rev. 11/05, p. A31). 

6(b) Estimating Respondent Costs

(i) Estimating labor costs
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Labor costs for testing follow the testing labor cost assumptions of ICR 0783.54 and 

average out to $59.07 per hour across management, technical, and secretarial categories. This 

figure, which was initially based on the fees rule cost study of EPA laboratory expenses, 

matches very closely with an analysis based on rates for engineering managers, mechanical 

engineers, and secretaries (except legal, medical, and executive) from the May 2005 BLS 

National Industry-Specific Occupational Employment and Wage Estimates 

(http://www.bls.gov/oes/current/naics4_336100.htm , accessed August 22, 2006). With a 160% 

overhead multiplier, these are $81.38, $49.71, and $33.57, respectively. The labor cost analysis 

may be updated for the final ICR. 

(ii) Estimating Capital and Operations and Maintenance Costs

Operation and Maintenance costs are the non-labor costs associated with conducting 

the new tests that are anticipated for the full model year after the effective date of the new 

regulations. The O&M costs for conducting emissions tests follow the assumptions in prior 

ICRs in this series, with an improved figure for NMOG and HCHO analysis, totaling about 

$4,000 per vehicle, with another $3,600 for OBD compliance and $2,000 for each 

confirmatory test. The estimate also includes O&M items for evaporative emissions testing, 

and reporting and recordkeeping, with the baseline total coming to about $10,000 per 

activity (test group). Applied to the industry, the baseline O&M cost is $121,541 annually. 

The proposal reduces this figure by $44,650, down to $76,891. This is primarily due to 1) 

reduction in the number of test groups by 25%; and 2) savings of $1,750 in NMOG and 

HCHO testing per test group. 

(iii) Start-up Costs

“Startup” costs are one-time costs to implement the new requirements in the proposal that 

are applicable to the next model year conversions being certified or by the respondent converters 

after the effective date of the final rule. These startup burdens fall into two categories. 

First are startup costs to redesign the VECI label. This burden is an add-on to well 

established reporting requirements: manufacturers already submit similar label data to EPA. 

Once the new label templates are in place, we anticipate no increase in burden for this startup 

item. This part of the estimate costs new analysis and coding for 18 test groups, reduced to 14 

by the new rule. This is a small item, less than $10,000 for the industry, and is annualized and 

discounted at 7% in the cost estimate. 

Second are capital costs associated with the testing requirements. Because manufacturers 

vary widely in their existing testing facilities, their excess capacities, their work shift 

arrangements and availabilities, the real estate cost and land availabilities for hypothetical 

expansions, and their contractual arrangements with other testing facilities, CISD has for many

year now used the approximation that a facility capable of performing 750 FTP/HFET tests per 

year costs $4,000,000 and allocated this cost to each testing increment. This cost is then allocated 

over ten years and discounted at 7%. This methodology is considered conservative, because it 

assumes no excess capacity. Similarly, evaporative facilities are costed at $3,000,000 to conduct 

900 evaporative tests a year. While most converters work through contractors whose contract 
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costs do not break down costs in this manner, for consistency the analysis in the Certification IC 

series is continued here. 

Primarily due to the reduction in the number of test groups (slightly offset by the new 

labeling startup) he total non-depreciated capital costs for the conversion program of $114,600 

are reduced by $45,417 to $69,183.

6(c) Estimating Agency Burden

The emission and fuel economy compliance programs are primarily administered by

EPA’s Compliance and Innovative Strategies Division and Laboratory Operations Division. 

Approximately 47.5 full time employee equivalents are directly involved in the combined 

emission and fuel economy light-duty, motorcycle, and other, secondary programs; their 

cost is approximately $5.9 million, including benefits but not overhead. EPA also 

participates in a program whereby the agency contracts with an organization that provides 

qualified persons to perform duties for the agency that are not performed by EPA 

employees. The cost associated with these persons who work directly on these programs is 

approximately $0.23 million, excluding overhead. Overhead percentage for the entire 

division is approximately 16.9%, yielding an estimated total agency labor cost of $7.17 

million. The total non-capital costs for the light-duty and motorcycle programs, including 

direct and indirect labor, operations and maintenance, and overhead, is estimated as $11.14 

million for FY 2007. 

Implementation of the new alternative fuels rule will be carried out by existing staff.

Other ongoing database management, oversight, and certification activities are part of the 

fuel economy and emissions program Agency baseline. All EPA labor estimates are based 

on Office of Personnel Management draft annual pay rates effective January, 2008, with a 

1.6 multiplier for overhead based on EPA’s latest fees cost allocation study (1.37 indirect 

program cost overhead times 1.16 overall EPA overhead). This estimate does not include 

Agency burdens incurred prior to the effective date of the rule, such as costs of developing 

the rule and preliminary consultations with converters. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

From the above discussion the following total burden and cost estimates can be 

calculated. (Due to the diverse nature of the converter industry, there is no typical or 

average respondent.)

6(e) Bottom Line Burden Hours and Cost

(i) Respondent Tally

[a] Overall Emissions IC

This analysis is against the Emissions IC baseline in ICR 0783.54. EPA has another 

rulemaking underway (Revisions to Reduce Emissions of Greenhouse Gases; EPA ICR 0783.56) 
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which will result in other changes.

[1] Existing authorization

RESPONDENTS 35

BURDEN HOURS 362,033

LABOR COST $6,308,800

OPERATING COST $5,929,702

CAPITALIZED COST $2,256,127

TOTAL NON-LABOR COST $8,185,829

[2] After proposal

RESPONDENTS 35

BURDEN HOURS 340,091

LABOR COST $5,054,396

OPERATING COST $5,763,511

CAPITALIZED COST $2,233,795

TOTAL NON-LABOR COST $7,997,306

[3] Reduction in burden

BURDEN HOURS -21,997

LABOR COST -$1,254,404

OPERATING COST -$166,191

CAPITALIZED COST -$22,332

TOTAL NON-LABOR COST -$188,523

[b] Alternative Fuels Converters

[1] Existing baseline

RESPONDENTS 5

FAMILIES 36

BURDEN HOURS 29,738

LABOR COST $1,756,606

OPERATING COST $243,082

CAPITALIZED COST $32,630

TOTAL NON-LABOR COST $275,712

[2] After proposal

RESPONDENTS 5

FAMILIES (75% OF 18) 14

BURDEN HOURS 7,796

LABOR COST $502,202
13

OPERATING COST $76,891

CAPITALIZED COST $10,298

TOTAL NON-LABOR COST $87,189

[3] Reduction in burden

BURDEN HOURS -21,942

LABOR COST -$1,254,404

OPERATING COST -$166,191

CAPITALIZED COST -$22,332

TOTAL NON-LABOR COST -$188,523

[4] Reduction in burden applied to a hypothetical pre-proposal 18 family baseline

BURDEN HOURS -7,073

LABOR COST -$376,101

OPERATING COST -$44,650

CAPITALIZED COST -$6,017

TOTAL NON-LABOR COST -$50,667

(ii) Agency Tally

EMPLOYEES 47.5

CONTRACT LABOR COST $0.27 million

COST $11.1 million

6(f) Reasons for change in burden

The burden change is from changes in the baseline number of test groups and 

reductions in the capital and operations and maintenance costs and labor hours associated 

with implementing the new programs detailed in this draft ICR.

6(g) Burden Statement

The table in Section 6(e)(i)[b][2] presents the total estimated burden for the alternative 

fuels conversion light-duty program after the proposed rule: approximately 7,796 hours per year, 

with total annual capitalized and O&M costs estimated at $87,189. These represent a savings of 

21,942 hours and $188,523 over the existing alternative fuels light-duty baseline. The annual 

costs and hours for information collection activities by a given manufacturer under any of 

the options in this proposed rule depend upon manufacturer-specific variables, such as the 

number of different test groups and the number of vehicles tested. The estimated number

of likely respondent manufacturers is 5. The responses will be submitted annually and 

occasionally as a part of the existing EPA certification program. 

Burden means the total time, effort, or financial resources expended by persons to 
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generate, maintain, retain, or disclose or provide information to or for a Federal agency. 

This includes the time needed to review instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions 

and requirements; train personnel to be able to respond to a collection of information;

search data sources; complete and review the collection of information; and transmit or 

otherwise disclose the information. An agency may not conduct or sponsor, and a person is 

not required to respond to, a collection of information unless it displays a currently valid 

OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 

CFR Part 9.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including 

the use of automated collection techniques, EPA has established a public docket for this 

rule, which includes this ICR, under Docket ID number EPA-HQ-OAR-2009-0299. Submit 

any comments related to the ICR for this proposed rule to EPA and OMB. Submit your 

comments, identified by Docket ID No. EPA-HQ-OAR-2009-0299, by one of the following 

methods:

• www.regulations.gov: Follow the on-line instructions for submitting 

comments.

• Fax: (202) 566-1741. 

• Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Air 

and Radiation Docket, Mail Code 6102T, 1200 Pennsylvania Avenue, N.W., 

Washington, DC 20460, Attention Docket ID No. EPA-HQ-OAR-2009-0299. 

In addition, please mail a copy of your comments on the information 

collection provisions to the Office of Information and Regulatory Affairs, 

Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 

7th St. NW., Washington, DC 20503.”

• Hand Delivery: Docket Center, (EPA/DC) EPA West, Room B102, 1301 

Constitution Ave., NW, Washington, DC., Attention Docket ID No. OAR2009-0299. Such deliveries are only accepted during the Docket’s normal 

hours of operation, and special arrangements should be made for deliveries 

of boxed information 

Docket ID No. EPA-HQ-OAR-2009-0299, is available for public viewing at the Air And 

Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room 

is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Reading Room is (202) 566-1744, and the telephone number 

for the Air and Radiation Docket is also (202) 566-1744. An electronic version of the 

public docket is available through EPA Dockets (EDOCKET) at www.regulations.gov.